BEFORE THE

FEDERAL AVIATION ADMINISTRATION

___________________________________________

PETITION OF THE VREELAND INSTITUTE, INC.

FOR AN EXEMPTION OF CERTAIN FEDERAL AVIATION REGULATIONS

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS

Thomas S. Vreeland

The Vreeland Institute, Inc.

529 County Route 7A

Copake, NY 12516

Phone: (518) 620-6380

Email: tvreeland@taconic.net

Date: May 8, 2015

The Vreeland Institute, Inc.,

Petitioner. DOCKET NUMBER FAA-2015-_______
Hon. Michael Huerta

Administrator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, The Vreeland Institute, a New York educational not-for-profit corporation, hereby applies

for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow it to operate small

Unmanned Aircraft Systems (“sUASs”) under the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive

sUASs under controlled conditions in airspace that are 1) limited 2) predetermined 3) controlled as to

access and 4) would provide safety enhancements to the already safe aviation education and pilot

training programs presently using conventional aircraft. Approval of this exemption would thereby

enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirements for the

safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform

Act.

The requested exemption would allow the petitioner to operate unmanned aircraft systems (UAS) to

conduct a UAS Flight Instruction Program to introduce students to the elements of UAS operation from

a commercial and noncommercial perspective, and to explain how these operations must fit into the

National Airspace System. The exemption would allow the petitioner to operate unmanned aircraft

systems (UAS) to conduct aerial search and rescue and disaster relief operations in the United States, aerial imagery, research and development, and educational community outreach. The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act,

which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems

may operate safely in the national airspace system (NAS) before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determination, the Administrator must determine

which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to

national security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.
Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. § 45.23(b)

14 CFR § 61.3

14 C.F.R. § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F. R. § 91.119

14 C.F.R. § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b)

14 CFR § 91.205(b)

14 CFR § 91.215

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b) 3

Appendix 1 lists the FARs from which an exemption is requested and summarizes the justification for

each requested exemption.

Appendix 2 contains a summary of this exemption petition for use in the Federal Register.

Reform Act § 333 (a).

If the Administrator determines that such vehicles “may operate safely in the national airspace system,

the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace

system.” Id. § 333(c).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory

requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The

Administrator may grant an exemption from a requirement of a regulation prescribed under subsection

(a) or (b) of this section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds

the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704;

14 CFR §91.203 (a) (1).

The Petitioner:

The Vreeland Institute, Inc

Attn: Thomas S. Vreeland, Director

Telephone: (518) 620-6380

Email: tvreeland@taconic.net

Address: 529 County Route 7A, Copake, NY 12516
The Petitioner is a New York educational not-for=profit corporation: The Vreeland Institute, Inc. The

Institute conducts educational programs for PK-12 schools and students, international democracy

programs, environmental and conservation programs, and advanced technology programs for the

Department of Homeland Security. The Director of the Institute has had extensive experience and

training in in aerospace education, emergency operations, and advanced technology aviation systems. Additionally, the Director has a strong interest in sUASs and has been recreationally flying RC model

aircraft and sUASs for approximately 45 years, amassing hundreds of hours of flight time.

Proposed sUAS Operations:

The Vreeland Institute intends to establish a UAS Flight Instruction Curriculum and training program.

This program will introduce students to the elements of UAS operation from a commercial and

noncommercial perspective and explain how these operations must fit into the National Airspace

System (NAS). All UAS training and instructional activities will occur under tightly controlled conditions

on property that is more than five miles from any airport. Upon completion of The Vreeland Institute’s

program, students will be provided with a Certificate of Completion. This "Certificate of Completion"

does not permit the student to engage in commercial UAS activities that are not in accordance with the

FARs, but rather, is intended to be an acknowledgement that the student has successfully demonstrated

a complete understanding of UAS operations from a NAS perspective. This exemption request is an

opportunity to not only prepare UAS pilots for aviation and aerospace careers in the UAS industry, but

also to collaborate with the FAA to study and address training and qualification needs specific to the

UAS industry. Furthermore, The Vreeland Institute will coordinate and continuously update its

curriculum to take advantage of new guidance and regulations proposed and implemented by the FAA.

The Vreeland Institute is committed to ensuring that its instructional program not only is compliant, but

always reflects best practices in the UAS industry.

The Petitioner has formulated an operations plan to provide emergency management assistance to

Local, State and Federal entities. The plan is to employ sUASs for search and rescue (SAR),

Hazmat/CBRN management and emergency and disaster response. The unmanned sUAS platform

puts the power of aerial situational awareness directly into the hands of first responders. Real-time

video streaming can show not only the extent of the damage but may also warn responders of additional

hazards. Geo-tagged digital photographs provide an aerial record of ground truth. The Petitioner plans

to collect aerial imagery for pond and forest management activities, conduct remote sensing research

and development and extend other programs to have a school based educational outreach component.

Under these plans, the Petitioner will employ sUASs, flying below 400 feet AGL and never within 5 miles

from an airport. They will operate only within the line of sight of the operator and will only operate in

populated areas for life and safety reasons and under the control of the operator. Flights will be remote

from noise sensitive areas such as parks, schools, hospitals, and churches. Flights will be only

conducted in permissible weather – rain, snow, or winds above 12 mph will terminate the flights. Prior to

operating the sUASs all necessary pre-flight checks will be conducted. Safety will be the paramount

concern during flight operations. Petitioner proposes that PIC for these sUAS may be an FAA certified pilot, or an individual who has

passed the Private Pilot, Standard Ground Instructor (SGI), or Advanced Ground Instructor (AGI)

Knowledge Examination. This will assure an understanding or risk management principles and

National Airspace System (NAS) requirements.
Vehicles

The Petitioner will fly two types of sUAS: Fixed wing Raven RC Aircraft and Parrot Bebop Quadcopters.

These vehicles have the built in capability to limit the height they fly above the ground, to limit the radius

of the distance they fly from the operator, and to exclude them from class B, C, and D airspace as well

any TFR’s (Temporary Flight Restricted) areas. The vehicles also have the built-in capability to return to

the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of

the height, radius, or airspace limitations programmed into them.

The vehicles weigh under five pounds and have a top speed of about 20 knots. The Raven has a single

fixed pitch propeller, and a conventional monowing airframe. The Parrot Bebop Quadcopter has four

fixed-pitch rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer smart

battery. Appendix 3 contains brief descriptions of the sUASs to be used by the Vreeland Institute for

commercial air operations.

Flight profiles

The petitioner will preset both vehicle types so they will fly no more than 400 feet above ground level,

nor more than 1500 feet away from the operator. The PIC (Person in Control) will carefully pre-flight the

vehicle before each mission to assure that its compass and GPS system are properly calibrated and

that the return-to-home feature, altitude, and radius limitations are functional. No operations will be conducted in controlled airspace. In the unlikely event that a manned aircraft flies

below 400 feet AGL where the Petitioner is operating its sUASs, the operator will keep both the vehicle

and manned aircraft in sight and avoid the manned aircraft.

Public interest

Granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of sUAS into the

National Airspace System advances the public interest. The Committee Report leading the House to

adopt H.R. 658 said: "The successful integration of unmanned aircraft systems (UAS) into the National

Airspace System (NAS) can support more than 23,000 high-paying jobs in the United States. . . . The

absence of a plan to integrate UASs into the NAS is a barrier to such job creation . . . ." Granting the

Petition represents a step toward such integration, in the absence of a comprehensive regulatory

regime for sUAS, and thus would serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in emergency response and disaster relief activities, one

in which the responders themselves have a tool to safely, quickly and remotely assess a situation

without placing lives in harm’s way. Likewise, explosive ordinance disposal (EOD) robots have saved

countless lives since their inception, an accomplishment that will become commonplace for aerial

assessments as well. 3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating new

safety techniques and tactics with new aeronautical technology, thereby improving the efficiency of

emergency responders and disaster relief personnel around the world and making for a safer society.
4. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies

advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging

and developing civil aeronautics, including new aviation technology." Granting the Petition will enhance

FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the

United States because of the rapid pace of innovation in aeronautical and associated technologies,

followed by their commercialization and their introduction into the marketplace. The sUAS technology

that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology.

Preventing it from using this in air commerce subverts achievement of the goal.

5. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into

the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012,

specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS

technologies. It mandated several steps by the FAA to accelerate the availability of these technologies

in the National Airspace System, thereby representing a congressional determination that the public

interest is served by making these technologies more widely available at the earliest practicable date.

The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional

mandate and meeting its obligation to enhance the public interest by making new technologies available

by allowing the use of sUAS technologies in a manner that protects the public and the rest of the

aviation community from significant risk.

The commercial activities by Petitioner proposed in this Petition represent contributions to new forms of

air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act.

6. Granting the Petition will enhance aviation safety, thereby advancing the public interest. The

Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to

aircraft in the National Airspace System and to persons and property on the ground. Granting the

Petition will enable the Petitioner to be a role model and an exemplar for safe commercial sUAS

operations.

Users of the National Airspace System are confronted by mounting threats from sUAS being flown in

defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe

operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying

the hazards to manned aircraft and to persons and property on the ground.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and

operation within visual line of sight, and national security. The Petition justifies grant of the requested

exemptions to allow the Petitioner to engage in commercial activities using sUASs. Respectfully submitted,

Thomas S. Vreeland, Director

The Vreeland Institute
APPENDIX 1

Regulations from which the exemption is requested:

FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display

registration number on

vehicle

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification

requirements and procedures

Designed for manned aircraft; not

suitable for off-the-shelf sUAS

14 CFR § 61.3 Requirement for pilot

certificate

Part 61 requirements designed for

manned aircraft, not sUAS; petition

describes training for sUAS operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not

suitable for off-the-shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to be

available in the cockpit

No one aboard to read manual. 14 CFR § 91.103(b) Requirement for crew

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls

during flight instruction

No one aboard to operate controls

14 CFR § 91.119 Minimum altitudes for safe

flight

Safety requires operation below these

altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration

and airworthiness certificates

to be onboard

No one aboard to read certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b) 3

Maintenance Inspections Applies to aircraft with Airworthiness

Certificate. Operator will maintain sUAS.
APPENDIX 2

Summary of Exemption Request for Federal Register:

Applicant, The Vreeland Institute, Inc., seeks an exemption from the following regulations Part 21; 14

C.F.R. § 45.23(b); 14 C.F.R. § 61.113 (a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2);14 C.F.R. §

91.103; 14 C.F.R. § 91.109(a); 14 C.F.R. § 91.119(b);14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14

C.F.R. § 91.203(a) and (b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2);

14 C.F.R. § 91.417(a) and (b), as established by the FAA, in order to commercially operate an

unmanned aerial system weighing less than 5.5 lbs. and operating at a maximum altitude of 400 feet

AGL for sUAS flight training, and for other commercial uses including but not limited to aerial imagery,

research and development, and search and rescue.
APPENDIX 3

Small Unmanned Aerial System (sUAS) primary trainers:

Quadcopter Fixed Wing

Parrot Bebop Raven RC

 Wingspan: 38 cm

 Length: 33 cm

 Weight: 420 g

 Flight Control: Parrot and GNSS

 Speed: 13 m/s  Radio Control: WiFi 802.11 a/b/g/n/ac  Motors: 4 brushless Outrunner motors  Camera: 14 Mpix HD

 Wingspan: 1300mm

 Length: 1660mm

 Weight: 900~1000 g

 Flight Control: ArduPilot 2.6

 Wing Loading: 30~34g dm^2

 Radio Control: 3 ch 2 servos  Motors: 2835~3035 size

 Camera: GoPro 4